Description
Forty-two of the world's leading transfer pricing professionals offer their advice and insights on how to navigate complex issues, including:
* When is an APA Advantageous?
* Understanding the New U.S. Services Regulations
* Transfer Pricing Implications of Reorganizations
* Valuing Intangibles Under Cost Sharing Arrangements
* How to Apply the Best Method Rule
The book also provides a country-by-country review of transfer pricing laws in a dozen major economies, addressing questions such as:
* What transfer pricing methods are accepted?
* Do the local tax authorities favor a given method?
* What dispute resolution mechanisms are available?
* Are APAs allowed and, if so, what are the rules?
* To what extent are international guidelines followed?
* How is the acceptability of comparables determined?
* What are the documentation requirements?
* How are non-compliance penalties calculated?
Table of Contents:
I Introduction
From the Editor
Overview of the Transfer Pricing Analysis Process
Executive Summaries
II Advance Pricing Agreements
Using Advance Pricing Agreements to Mitigate Transfer Pricing Risk
Documentation Requirements, FIN 48, and APAs: Have New
Disclosure Requirements Introduced Risk Factors that Make
Advance Pricing Agreements More Advantageous?
III Cost Sharing Arrangements
A Discussion of the Latest IRS Views on the Investor Model and
Intangible Valuation Under Cost Sharing Arrangements
IV Intangibles
Issues Arising in the Application of the Comparable Uncontrolled
Transaction Method
Marketing Intangibles and Transfer Pricing: Economic Issues and Tax Enigmas
Marketing Intangibles Require Close Legal and Tax Scrutiny
V Organizational Structure
Business Restructuring— “Conversion” Issues and a Framework for Analysis
Applying the Arm’s Length Principle to Valuing “Exit Charges”
Business Restructuring Expenses — Tax Challenges and Opportunities
VI Services
Key Considerations when Applying the New Service Regulations –
Treas Reg § 1482-9T
A Practical Process and Approach to Implementing the New
Transfer Pricing Service Regulations
VII Trade Finance
Commodities Trading and Global Dealing: Transfer Pricing Challenges
and Proposed Methods
VIII Treaties
Mandatory Arbitration Procedures: A New Tack for Resolving Double
Taxation Disputes between Competent Authorities
IX Country Overviews
Overview of the Transfer Pricing Environment in Argentina
Transfer Pricing in Belgium
Transfer Pricing in Brazil
Overview of Canadian Transfer Pricing
China’s Transfer Pricing Regime
Denmark – Transfer pricing overview
Overview of Transfer Pricing in France
German Transfer Pricing Rules in Practice
Transfer Pricing in Mexico
Transfer Pricing: The Dutch Approach (the Netherlands)
Transfer Pricing in Norway
UK Tax Authorities Plan Stricter Enforcement of Transfer Pricing Rules:
What will these Changes Mean for International Companies?
X Supplemental Materials
United States Advance Pricing Agreement Revenue Procedure
(IRS Revenue Procedure 2006-9)
European Union Transfer Pricing Documentation Guidelines (EU TBD)
XI Glossary
A Note About Transfer Pricing Terminology
Advance Pricing Agreements
Arm’s-Length Principle
Best Method Rule
Comparable Profits Method
Comparable Uncontrolled Price Method
Cost Plus Method
Cost of Services Plus Method
Cost-Sharing Arrangements
Gross Services Margin
Indirect Costs
Intangible Property
Profi t Split Method
Related-Party Transaction
Resale Price Method
Services Cost Method
XII Directory of Contributors
Brian Andreoli
Svein G Andresen
Robert D Baldassarre
Anthony J Barbera
Marius Basteviken
Anjali Bhasin
Patrick Breslin
Valérie Bugault
George Carlson
Jose Casas Chavelas
Patrick Cauwenbergh
Pamela T Church
Jeffrey Cole
Luis Coronado
Christopher Desmond
Hareesh Dhawale
Horacio Dinice
Pierre-Jean Douvier
Sean Foley
L David Fox
Frank M Gasparo
Sheila Geraghty
Tamara Berner Gracon
Michael Granfield
Thijs Heijenrath
Tobin Hopkins
Erik Jan van Sten
Ted Keen
Elizabeth King
Andreas Köster-Böckenförde
Ryan Lange
Marc M Levey
Fernando Pereira de Matos
Niels Melius
Robert Miall
Alexander R T Odle
Danny Oosterhoff
Michael Plodek
Silvia B Rodriguez
J Linwood Smith
Monique van Herksen
Jens Wittendorff
PEOPLE WHO BOUGHT THIS BOOK ALSO BOUGHT
Ken Parker
Global Business Information Strategies, Inc.
Global Business Information Strategies, Inc. (GBIS), a Massachusetts corporation,was founded by Ken Parker, a veteran of the business information services industry. Global Business Information Strategies, Inc. helps business-to-business information providers target their publications and services at the research needs of company executives. We help publishers to reduce the cost per order for new subscription and book sales, we help software providers to identify key decision-makers who would benefit from their products, and we provide assistance to conference organizers in increasing the participation rates and profitability of their events.
